ML20209C903
| ML20209C903 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Diablo Canyon |
| Issue date: | 04/20/1984 |
| From: | Priebe R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Matthews D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20150F500 | List:
|
| References | |
| FOIA-86-391 CLI-84-04, CLI-84-4, NUDOCS 8405010248 | |
| Download: ML20209C903 (3) | |
Text
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APR 2 0 ISS. '
SO-3d3 MEMORANDUM FOR:
David 8. Matthews, Acting Chief Emergency Preparedness Branch Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement THRU:
Kenneth E. Perkins, Chief g q gggp Incident Response Branch Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement FROM:
Ray F. Priebe, Chief Section B Incident Response Branch Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
SUBJECT:
DIABLO CANYON - COMMISSION ORDER REGARDING CONSIDERATION OF EARTHQUAKES AND EMERGENCY PLANNING The enclosed is provided per your request for assistance in preparing a
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response to the issues raised in Commission Order CLI-84-4.
O Ray F. Priebe, Chief Section B Incident Response Branch Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
Enclosure:
As stated cc w/ enclosure:
E. L. Jordan, IE DISTRIBUTION DCS IRB File DEPER Rdg.
SSchwartz KPerkins RPriebe I
IRB:OpER:IE I'RB/0EPER:IE RFPriebe:kw KtPdrkins 04/'.o/84 04/Jc/84 g ko'n8M*6D8893 SW Foh -WI e-so A - 130
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Issue 1 "whether NRC emergency planning regulations can and should be read to require some review of the complicating effects of earthquakes on emergency planning for Ciablo Canyon;"
Consistent with the Commission ruling in the San Onofre case (CLI-81-33), the staff still considers that the NRC regulations do not, and should not, contain requirements for considering the effects of earthquakes on emergency planning for nuclear power plants.
The applicable emergency planning regulations in 10 CFR 50.47 and in Appendix E to Part 50 contain no explicit reference to any seismic considerations.
Although previous correspondence to the Commission contained thorough documen-tation of the basis for the staff's position, it also^ contained certain staff statements and intended actions which clouded whether the staff continued to hold to the above position and whether this is a closed item.
The staff statements referenced here are the following:
1.
Continuing staff efforts on the effects of earthquakes on emergency planning for nuclear power plants, particularly in the case of Diablo Canyon.
2.
A staff summary statement to the effect that "further clarification or refinement of current requirements and guidance might reduce the C
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impairment of emergency response to consequences resulting from earthquakes beyond the SSE, but the value of such reduction is uncertain."
The first item above was prompted by a request from Commissioner Ahearne in a March 1, 1982 memorandum rather than from any regulatory requirement.
The basis for the staff's ef fort stems from the following stategf ts contained
- therein,
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"... plans should be designed so they have flexibility and can provide protection even in the event of a plant accident at the same time as the
' occurrence of a natural phenomenon...which would be expected to occur at least once in the lifetime of a plant.
The objective is not to develop new requirements to assure the plans will function normally during these disasters.
Rather, it is to describe techniques for examining the flexi-bility of the plans so we can evaluate the extent to which plans remain capable even in the face of such once in a lifetime events."
The second statement above can be generalized to almost any area having an impact on protection of the pubile health and safety.
However, because of the cost benefit considerations, this statement was in no way intended to precipi-tate changes to the NRC's rules and regulations regarding emergency planning.
Rather, it was part of a summary statement characterizing the totality of the staff's consideration of the subject - it was not a recommendation to promulgate additional regulatory requirements.
It is not the purpose of this memorandum to rehash the exhaftstive treatment of the subject presented in previous memorandums to the Commission.
- However, certain salient conclusions are noteworthy:
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t
.8 1.
Earthquakes of magnitude less than or equal to the SSE are unlikely to pose any radiological hazard to the environs.
2.
Earthquakes larger than the SSE, even though highly unlikely, would not result in radiologic &l consequences outside the spectrum of accidents considered in the analysis (NUREG-0396) which provides the planning base presently used by State and local authorities for their emergency preparedness programs.
3.
The probability of a serious seismic event coincident with a significant plant accident from a non-seismic cause is vanishingly small.
4.
Statutory obligations require State emergency planners to consider measures responsive to special environmental characteristics, such as seismic events, to an extent commensurate with their likelihood of occurrence and the resources available.
Finally, no matter what degree of protection is afforded by the plant design and construction, as well as the in place emergency preparedness for areas of potentially high seismic activity, there will always be a residual risk to the public from the effects of severe earthquakes on a nuclear power plant, which the decisionmakers must accept or reject.
Based on our previous studies and analyses, the staff considers that the current residual risk is acceptable and that no additional regulations are required in the area of emergency planning for seismic events.
Issue 2 "if the answer to Issue 1 is no, should such a review be performed for Diablo Canyon on the ground that it presents special circumstances under 10 CFR 2.758.
If so, what are the special circumstances that would permit consideration of the effects of earthquakes on emergency planning for Diablo Canyon?"
The same discussion and conclusion presented above applies to Issue 2.
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